Lost in Translation: Interpreting Diverging but Equally Authentic CISG Texts

Abstract

There are six different authentic CISG texts, which are to be deemed equally authoritative. Despite the efforts during the diplomatic conference, the texts encompass divergencies amongst their provisions. The issue raises a question as to the uniform interpretation of the CISG. This article examines some of the specific instances of discrepancy and how to resolve them under the CISG and the Vienna Convention of the Law of Treaties. It also discusses the issue of how parties may expressly or impliedly choose under Article 6 CISG a specific authentic or nonauthentic version of the CISG to govern their contract